4
Independent and Supervised Practice of Counselors in Other Health-Care Systems
As part of the committee’s statement of task, the Department of Defense requested that it assess the extent to which mental health counselors are authorized to practice independently under some federal programs other than TRICARE and under the Federal Employee Health Benefits Program (FEHBP). It was also asked to identify the states that had laws requiring private insurers to cover, or offer coverage of, the services of licensed mental health counselors. This chapter addresses those topics.
INDEPENDENT AND SUPERVISED PRACTICE UNDER OTHER FEDERAL PROGRAMS
The statement of task identified four federal programs for attention: Medicare, the Department of Veterans Affairs (VA) program, the Indian Health Service (IHS) program, and Head Start (HS). The text below briefly reviews their policies and those of the US Public Health Service (PHS) regarding the practice of counselors.
Medicare
Practice Under Medicare
Medicare is a federally administered health insurance program for people 65 years old or older, people under 65 years old who have speci-
fied disabilities, and people of any age who have permanent kidney failure (CMS, 2009). The program covers the cost of mental health–care visits with physicians, clinical psychologists, clinical social workers, clinical nurse specialists, nurse practitioners, and physician’s assistants (CMS, 2002). Those health-care professionals are recognized as independent providers of mental health services under Medicare regulations.
Medicare does not recognize licensed professional counselors as independent providers, so they are not directly reimbursed through the program. Provisions in several bills that have been introduced in the House of Representatives and the Senate would have added counselors and some other mental health professionals to those eligible to provide services (CRS, 2007), but the provisions have not been enacted into law. As of October 1, 2009, bills that would grant that authority were under consideration in both chambers (HR 1693 and S 671).
Medicare beneficiaries can receive services from counselors in two ways. They can visit practitioners and pay for the expense out of pocket, or the counselors can provide treatment through the Part B “incident to” clause. The latter method allows counselors to bill Medicare through physicians or psychologists. To be covered by the clause, a service must be an integral, although incidental, part of a physician’s or psychologist’s services; the counselor must work in the same facility as a physician or psychologist (as either an employee or independent contractor of the physician or psychologist or the facility); and the counselor must be under the supervision of the physician or psychologist. Supervision means that “the physician/psychologist must be present in the facility and immediately available to provide assistance and direction while the aide is performing services” (ACA, 2009a). The physician, psychologist, or facility bills Medicare for the service, and the counselor is paid as an employee or contractor of the physician, psychologist, or facility.
Association Between Independent Practice Authority Under the Medicare Program and Under TRICARE
The committee’s statement of task directed it to review the relationship, if any, between recognition of mental health professions under the Medicare program and independent practice authority for such professions under the TRICARE program. Only one non-doctoral-level mental health profession—clinical social work—has been granted independent practice authority by both TRICARE and Medicare. Clinical
social workers were first granted authority under TRICARE in the FY 1983 Department of Defense Authorization Act (Public Law 97-252) and were later granted recognition under Medicare in the Omnibus Budget Reconciliation Act of 1989 (Public Law 101-239). Congress directed the authority to be granted in both circumstances. Marriage and family therapists have been granted independent practice authority only under TRICARE, through a provision of the FY 1991 Department of Defense Authorization Act (Public Law 101-510); they have not been granted recognition under Medicare. Licensed professional counselors have not been granted independent practice authority under either TRICARE or Medicare.
Department of Veterans Affairs
VA, through programs of the Veterans Health Administration, provides a comprehensive array of health-care services to about 7.9 million enrollees (VA, 2009). In December 2006, the Veterans Benefits, Healthcare, and Information Technology Act was signed into law (Public Law 109-461). It established the recognition of mental health counselors as mental health–care specialists under health-care programs operated by VA. It also established the recognition of licensed marriage and family therapists as mental health–care providers. Although VA has long employed rehabilitation counselors to provide readjustment-counseling services to veterans, it did not previously recognize these professional groups. The new law allows VA to hire licensed mental health counselors at the same level as clinical social workers and allows counselors to apply for supervisory positions that are open to clinical social workers and marriage and family therapists. Rather than placing them in the same occupational category as other mental health professionals, the VA Under Secretary for Health approved, in February 2009, the creation of a new occupational category or categories for licensed professional counselors and marriage and family therapists to be hired by VA (ACA, 2009b). Details of those categories had not been established at the time the present report was completed.
Indian Health Service
IHS is an agency in the Department of Health and Human Services (HHS). It is the principal federal health-care provider and health
advocate for American Indians and Alaska Natives and is responsible for providing federal health services to about 1.9 million people who belong to 562 federally recognized tribes in 35 states. The goal of IHS is “to assure that comprehensive, culturally acceptable personal and public health services are available and accessible to American Indian and Alaska Native people” (IHS, 2009c). Because this population experiences considerable disparities with regard to psychological health compared with the general population and because over one-third of the service demands in IHS facilities are related to mental health and substance abuse, IHS behavioral health programs are particularly important to the population.
IHS will accept a state license and the stipulated scope of practice for the license as criteria for the delivery of services in IHS facilities. In addition, individual credentialing agencies can further define and limit the scope of practice for some professionals, including advanced-practice nurses and other allied-health professionals in the federal system. Over 60% of mental health treatment and almost all substance-abuse counseling takes place at the tribal level (IHS, 2009a). IHS credentialing standards serve as the base guidelines for tribes, but they are able to establish additional or different standards if they choose. Regardless of the standards used, the focus is always on the scope of practice, particularly at the credentialing level.
Behavioral health programs in IHS include community-oriented clinical and preventive services. The delivery of needed services is complex, however, and often divided among tribal, federal, state, local, and community-based providers. In addition, the availability of services varies among communities; those who live in rural areas are most adversely affected by problems of availability and lack of appropriate care. Overall, the behavioral health needs of this population are largely unmet, and adequate services are scarce and access to appropriate care difficult and expensive (IHS, 2009a).
The policy of IHS is to use interdisciplinary mental health teams that comprise representatives of several mental health disciplines to provide comprehensive services to the American Indian and Alaska Native population. Mental health providers identified in IHS include psychiatrists, psychologists, psychiatric nurses, psychiatric social workers, other social scientists, and mental health technicians. IHS policies stipulate that all mental health staff working in IHS facilities must meet the minimum educational requirements set forth by the Civil Service or
Commissioned Corps. Mental health professionals and consultants must also be licensed in accordance with existing PHS requirements, which stipulate that all health-care providers must be licensed, certified, or registered in their disciplines (PHS-CC, 2008a). Clinical privileges are recommended for mental health technicians, mental health counselors, and psychiatric nurses and allow them to provide clinical mental health services independently of physician supervision.
Licensing and credentialing standards for mental health professionals in IHS center on educational requirements, but clinical privileging standards have also been established for IHS providers on the basis of licensure, training, experience, and current competence “for all individuals who are permitted by law and by a facility to provide patient care services independently in a facility whether or not they are members of the medical staff ” (IHS, 2009b).
Clinical privileges are granted and maintained on the basis of demonstrated clinical competence, including an assessment of relevant findings from quality-assurance activities, peer recommendations, measured assurance that people consistently provide services within the scope of their privileges, a review of privileges at least every 2 years, and established procedures for the denial, limitation, or change in clinical privileges granted to any health-care provider. In addition to retaining their clinical privileges, mental health professionals must participate in continuing education to maintain their licensure and to continue providing services in IHS facilities.
Head Start
HS is a national program administered by HHS that “promotes school readiness by enhancing the social and cognitive development of children through the provision of educational, health, nutritional, social and other services to enrolled children and families” (HHS, 2009). Although the program does not have a formal policy regarding the use and independent practice of licensed professional counselors, it follows the rules of the states in which mental health services are being provided. HS provides grants to local agencies that agree to follow HS regulations in implementing their programs. The grantees determine how they will use their grant funds on the basis of local needs and resources but must ensure that they meet HS regulations regarding making mental health consultation available onsite. HS program-performance standards (fed-
eral regulations) require that a grantee’s mental health services be supported by staff or consultants who are licensed or certified mental health professionals with experience and expertise in serving young children and their families.
Programs must recognize that state licensure and certification systems review a professional’s training and experience and describe the scope of services that a professional is qualified to provide to children and families in the states. HS grantees are not required to provide all mental health services that a child may need but are encouraged to identify local mental health resources that can provide such services. Overall, HS does not act as a primary provider of mental health services but rather as a funder of entities that may then contract themselves out to provide services. Some other entities that may fund provision of services under specific circumstances—Medicaid, for example—may have their own policies and procedures that drive the scope of practice or billing rules.
US Public Health Service
The Commissioned Corps of PHS is one of the seven uniformed services of the United States. Among its primary missions is to provide health care to underserved populations. Its officers are placed in various career fields—such as medicine, nursing, dentistry, and environmental health—depending on their training (PHS-CC, 2009a). One field, health services, includes a variety of professionals, including such clinical specialists as psychologists, social workers, physician assistants, and optometrists and such nonclinical specialists as hospital administrators (PHS-CC, 2008c).
The Corps has a goal of expanding its active-duty strength to 6,600 officers. Some 5% of that number, or 330, are to be officers in the mental health functional group (PHS-CC, 2009b). As of May 15, 2007, the Corps had 108 clinical social workers and 14 clinical psychologists in its health-services field (PHS-CC, 2007). Psychiatrists and psychiatric nurses also serve in the Corps, but their numbers are not publicly available (PHS-CC, 2009c). The title “licensed professional counselor” is not listed among its professional categories.
INDEPENDENT AND SUPERVISED PRACTICE UNDER THE FEDERAL EMPLOYEE HEALTH BENEFITS PROGRAM
Overview of the Program
The FEHBP was established by law in 1959 and became active in 1960 (OPM, 2009d).1 It is administered by the Office of Personnel Management (OPM) and provides federal employees and eligible family members with a variety of privately run, government-subsidized insurance plans. Among the plan types are fee-for-service (FFS) plans, high-deductible health plans, and health maintenance organization (HMO) plans (OPM, 2009c). The selection of plans available to a particular employee depends both on geographic area and on the employing government organization.
Plans may not turn down employees or eligible family members because of preexisting medical conditions (OPM, 2009f ). In general, costs of the plan are split between the employee and the federal government; the government pays the smaller of 75% of the chosen plan cost or 72% of the average plan cost of all FEHBP enrollees (OPM, 2009b). Most federal employees are eligible for the FEHBP; exceptions are made for intermittent or temporary employees and employees of specific organizations, such as the Tennessee Valley Authority (OPM, 2009a). On retirement, qualified employees may continue enrollment in their current plan (OPM, 2009f ).
The FEHBP offers 10 FFS benefit plans that are available nationwide to all enrollees: the American Postal Workers Union “high,” Blue Cross and Blue Shield “standard” and “basic,” Government Employees Hospital Association “standard” and “high,” Mail Handlers “standard” and “value,” National Association of Letter Carriers “high,” and Special Agents Mutual Benefit Association “standard” and “high.” Each of those plans provides comprehensive coverage and has separate provider networks for which in-network providers have reduced costs. All plans offer international coverage (OPM, 2009f ).
Four other FFS benefit plans available nationwide through the FEHBP are sponsored by employee organizations, and enrollment is strictly limited to members of the organizations: Association “high,”
Foreign Service “high,” Panama Canal Area “high,” and Rural Carrier “high” (OPM, 2009f ).
Finally, the FEHBP includes a set of plans that are available only to subscribers in particular states. The number of plans and the services offered vary widely among the states. For example, eligible California residents have a choice of plans available through Aetna, Blue Cross, Blue Shield, Health Net, Kaiser Foundation, PacifiCare, and UnitedHealthcare; Texas residents have access to Aetna, Firstcare, Humana, PacifiCare, and UnitedHealthcare plans; and Pennsylvania residents can choose from Aetna, Geisinger, HealthAmerica, Keystone, and University of Pittsburgh Medical Center plans (OPM, 2009g). The coverage area, including the number of states where coverage is offered, varies among plans. Altius Health Plans, for example, limits coverage to subscribers in particular sections of Utah, Idaho, and Wyoming, while Aetna Healthfund provides insurance plans in all 50 states and the District of Columbia (Table 4.1).
The mental health services and providers covered by the plans differ by care organization, options purchased, and the state in which the plan was purchased. It may also vary from year to year.
Program Policies Regarding Independent Practice
The law governing the FEHBP lists licensed health-care providers whom plan enrollees must be free to see without physician referral or supervision (Table 4.2; 5 USC § 8902(k)(1)). HMO plans are exempted from the rule because a key feature of them is that a primary-care provider coordinates and refers specialist care (5 USC § 8902(k)(3)). Qualified clinical social workers—defined as those who have met state licensing requirements, national certification requirements in the absence of state licensing procedures, or “equivalent requirements” as determined by OPM—are among the providers whose services without physician supervision or referral must be covered (5 USC § 8901(11)). Except in states designated by OPM as underserved (Table 4.3), FEHBP plans are not explicitly required to cover licensed professional counselors, although the law allows insurance plans to voluntarily cover other health professionals’ (including counselors’) services without physician supervision or referral, provided that the professionals are appropriately licensed or certified by state or federal law (5 USC § 8902(k)(1) and (2)). In underserved states, FFS, but not HMO, plans must cover all state-
TABLE 4.1 Coverage of Licensed Mental Health Counselors in FEHBP Nationwide and Selected State Insurance Plans
2010 Federal Insurance Plans |
FEHBP Plan Codes |
Licensed Mental Health Counselors Coverage |
Plan Details (Provider Definitions or Listed Benefits) |
NATIONWIDE FEE-FOR-SERVICE PLANS—OPEN TO ALL |
|||
Blue Cross and Blue Shield Service Benefit Plan |
10, 11 |
Yes |
Mental health or substance-abuse professional: a professional who is licensed by the state where the care is provided to provide mental health or substance-abuse services within the scope of the license |
|
|
|
Benefits include professional services, including individual or group therapy, provided by licensed professional mental health practitioners and substance-abuse practitioners when acting within the scope of their licenses |
Government Employees Hospital Association Benefit and High Deductible Health Plans |
31, 34 |
Yesa |
Benefits include individual or group therapy by psychiatrists, psychologists, clinical social workers, licensed professional counselors, and marriage and family therapists |
National Association of Letter Carriers |
32 |
Noa |
Benefits include outpatient professional services, including individual or group therapy by such providers as psychiatrists, psychologists, and clinical social workers |
Mail Handlers Benefit Plan Value and Consumer Option |
41, 45, 48 |
Yes |
Benefits include outpatient professional services, including individual or group therapy by providers approved by the managed in-network vendor; may include services by a licensed professional counselor or licensed marriage and family therapist |
2010 Federal Insurance Plans |
FEHBP Plan Codes |
Licensed Mental Health Counselors Coverage |
Plan Details (Provider Definitions or Listed Benefits) |
Special Agents Mutual Benefit Association |
44 |
Yesa |
Benefits include outpatient professional services by such providers as psychiatrists, psychologists, and clinical social workers |
American Postal Workers Union Health Plan |
47 |
Yes |
Benefits include professional services, including individual or group therapy by such providers as psychiatrists, psychologists, licensed social workers, and licensed intensive outpatient treatment centers |
NATIONWIDE FEE-FOR-SERVICE PLANS—OPEN ONLY TO SPECIFIC GROUPS |
|||
Rural Carrier Benefit Plan Specific Areas |
38 |
Yesa |
Qualified clinical psychologist: a person who has earned a doctoral or master’s clinical degree in psychology or an allied discipline and who is licensed or certified in the state where services are performed; this presumes that a licensed person has demonstrated to the satisfaction of state licensing officials that he or she, by virtue of academic and clinical experience, is qualified to provide psychological services in the state |
Foreign Service Benefit Plan Specific Areas |
40 |
Yes |
Qualified clinical psychologist: a person who has earned a doctoral or master’s clinical degree in psychology or an allied discipline and who is licensed or certified in the state where services are performed (such as licensed professional counselors) |
2010 Federal Insurance Plans |
FEHBP Plan Codes |
Licensed Mental Health Counselors Coverage |
Plan Details (Provider Definitions or Listed Benefits) |
Association Benefit Plan Specific Areas |
42 |
Yes |
Qualified clinical psychologist: a person who has earned a doctoral or master’s clinical degree in psychology or an allied discipline and who is licensed or certified in the state where services are performed; this presumes that a licensed person has demonstrated to the satisfaction of state licensing officials that he or she, by virtue of academic and clinical experience, is qualified to provide psychological services in the state |
Panama Canal Area Benefit Plan Specific Areas |
43 |
Noa |
Benefits include outpatient services, including individual or group therapy by such providers as psychiatrists, psychologists, and clinical social workers |
SELECTED STATE-SPECIFIC INURANCE PLANS |
|||
UnitedHealthcare Insurance Company, Inc., serving AR, AZ, CA, CO, DC, FL, GA, IA, IL, KS, LA, MD, MO, MS, NC, NM, NV, OH, OK, OR, RI, TN, TX, VA, WA, WI |
E9 |
Yesa |
Benefits include professional services, including individual or group therapy by such providers as psychiatrists, psychologists, and clinical social workers |
2010 Federal Insurance Plans |
FEHBP Plan Codes |
Licensed Mental Health Counselors Coverage |
Plan Details (Provider Definitions or Listed Benefits) |
Aetna HealthFund, serving AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, RI, SC, SD, TN, TX, UT, VA, VT, WA, WI, WV, WY |
22 |
Yesa |
Benefits include individual and group therapy performed by such licensed providers as psychiatrists, psychologists, and clinical social workers |
Altius Health Plans, serving Utah (northern and southern parts of Utah), Idaho (Boise and eastern parts of Idaho), and Wyoming (Uinta County) |
9K |
Yesa |
Benefits include professional services, including individual or group therapy by such providers as psychiatrists, psychologists, and clinical social workers |
aPublicly available sources did not specify whether the services of licensed mental health counselors were covered. Listed information was obtained via telephone calls to company representatives. |
TABLE 4.2 Licensed Health-Care Providers Whose Services Must Be Covered by FEHBP Plans Without Requiring Physician Referral or Supervisiona
TABLE 4.3 States Designated as Medically Underserved by OPM for 2009a
licensed medical providers although the law does not indicate whether physician supervision or referral is necessary (OPM, 2009e).
Because there is no federal licensing process for mental health counselors, an FEHBP plan that wishes to recognize counselors can do so only in accordance with the laws and regulations of the states where they practice. The Foreign Service Benefit Plan, for example, is an FFS FEHBP plan that includes state-licensed professional counselors among its covered providers (AFSPA, 2009, p. 10). Being an FFS plan, it allows enrollees to visit any covered provider, including counselors, without first obtaining a referral from a physician. That particular plan, however, requires preauthorization for any mental health treatment besides medication management (AFSPA, 2009, p. 48). Table 4.1 lists the federal FFS plans and a sample of state plans and shows which plans include coverage for licensed mental health counselors.
State Laws, Regulations, and Policies Regarding Independent Practice
States differ in their laws, regulations, and policies regarding the independent practice of counselors. An April 2009 presentation to
the committee noted that 14 states require health plans to cover the services of licensed counselors and another six require plans to offer coverage; these are listed in Table 4.4 (Kaplan, 2009). Arkansas and Michigan laws include so-called “any-willing-provider”2 provisions that include counselors.
More generally, the scope of practice and range of services allowed vary in both their details and specificity. Alabama law, for example, provides relatively general guidance, stipulating that
[t]he use of specific methods, techniques, or modalities within the practice of a Licensed Professional Counselor is restricted to counselors appropriately trained in the use of these methods, techniques, or modalities. A licensed professional counselor or associate licensed counselor shall not attempt to diagnose, prescribe for, treat, or advise a client with reference to problems or complaints falling outside the boundaries of counseling services. (Alabama Board of Examiners in Counseling, 2003)
Nebraska, in contrast, allows only persons who hold the more rigorous Independent Mental Health Practitioner license to perform diagnoses. That license requires 3,000 hours of experience under supervision, “one-half of which is comprised of experience with clients diagnosed under the major mental illness or disorder category” (Nebraska Department of Health and Human Services, 2007). The illnesses and disorders are defined elsewhere as schizophrenia, major depressive disorder, bipolar disorder, delusional disorder, psychotic disorder, panic disorder, and obsessive-compulsive disorder (Nebraska Department of Health and Human Services Regulation and Licensure, 2004).
The array of services offered is constrained in some states. For example, California, which is scheduled to begin to license counselors in 2011, does not include the assessment or treatment of couples or families in a professional clinical counselor’s scope of practice unless the counselor “has completed all of the following additional training and education, beyond the minimum training and education required for licensure” (California State Senate, Senate Bill 788, 2009).
TABLE 4.4 States That Require Coverage or the Offering of Coverage of Counselors’ Services
States That Require Coverage |
||
Arkansas |
New Hampshire |
Virginia |
Connecticut |
Rhode Island |
Washington |
Maryland |
South Dakota |
Wyoming |
Massachusetts |
Texas |
|
Montana |
Utah |
|
States That Require That Coverage Be Offered |
||
Illinois |
Louisiana |
Missouri |
Kansas |
Maine |
Vermont |
States with Any-Willing-Provider Laws Addressing Counselors |
|
|
Arkansas |
Michigan |
|
SOURCE: Adapted from Kaplan (2009). |
Terminology also varies. Notably, Maine licenses Professional Counselors and Clinical Professional Counselors: both are permitted to “engage in private/independent practice” (Maine Office of Licensing and Registration, 2009), but only persons holding clinical licenses may “diagnose and treat mental health disorders” (Maine Revised Statues, Title 32, Chapter 119, § 13858).
All states allow counselors to practice independently at some level of licensure. Supervised practice is required for persons who hold “conditional,” “intern,” “provisional,” and like-titled licenses in the states that offer them. Those licenses are intended for persons who are beginning their professional careers and seeking to accumulate the experience needed for higher-level licenses and national certifications. Rules regarding whether counselors can perform diagnoses are more complicated. Most states explicitly include diagnosis in the scope of practice delineated in law or regulation. Three—Georgia, Idaho, and Illinois—do not use the term, and this leads to uncertainty. Maine and New Mexico permit those holding clinical licenses to perform diagnoses, Indiana prohibits counselors from making diagnoses but allows them to perform classifications according to the Diagnostic and Statistical Manual of Mental Disorders, and Nebraska permits only those holding licensure as a Licensed Independent Mental Health Practitioner to perform diagnoses.
REFERENCES
ACA (American Counseling Association). 2009a. Frequently asked questions: Medicare. (2.19.09). http://www.counseling.org/Files/FD.ashx?guid=1b2019e5-1ed1-4c9f-b0bb-9b92298fa368. (Accessed October 12, 2009).
ACA. 2009b. Progress on implementation of new Veterans Affairs law. http://www.counseling.org/PublicPolicy/PositionPapers.aspx?AGuid=682a95b9-d0be-4f6d-982a-97fa7ed80737. (Accessed October 28, 2009).
AFSPA (American Foreign Service Protective Association). 2009. Foreign service benefit plans. In Center for Retirement and Insurance Services. Washington, DC: US Office of Personnel Management. http://www.opm.gov/insure/health/planinfo/2009/brochures/72-001.pdf. (Accessed October 28, 2009).
Alabama Board of Examiners in Counseling. 2003. Definitions and clarification of terms. In Administrative Rules, Chapter 255-X-2. http://www.abec.state.al.us/PDFs/255_X_2_JULY_03.pdf. (Accessed January 8, 2010).
Carroll A, Ambrose JM. 2002. Any-willing-provider laws: Their financial effects on HMOs. Journal of Health Politics, Policy and Law 27(6):927-945.
CMS (Centers for Medicare and Medicaid Services). 2002. Medicare and your mental health benefits. Bethesda, MD: National Institute of Mental Health.
CMS. 2009. What is Medicare? http://www.medicare.gov/Publications/Pubs/pdf/11306.pdf. (Accessed October 12, 2009).
CRS (Congressional Research Service). 2007. The Mental Health Parity Act. A Legislative History. CRS Report for Congress. Order Code RL33820. Washington, DC: US Government Printing Office.
HHS (Department of Health and Human Services). 2009. About the Office of Head Start. http://www.acf.hhs.gov/programs/ohs/about/. (Accessed October 12, 2009).
IHS (Indian Health Service). 2009a. Behavioral health. http://info.ihs.gov/Bhealth.asp. (Accessed October 28, 2009).
IHS. 2009b. Mental health program. In Indian health manual. Rockville, MD: Department of Health and Human Services. Part 3, Chapter 14.
IHS. 2009c. Indian Health Service introduction. http://www.ihs.gov/PublicInfo/PublicAffairs/Welcome_Info/IHSintro.asp. (Accessed October 28, 2009).
Kaplan D. 2009. Licensed mental health counselors and the TRICARE Program. Presentation to the Institute of Medicine Committee on the Committee on the Qualifications of Professionals Providing Mental Health Counseling Services Under TRICARE, April 9. http://www.iom.edu/~/media/Files/Activity%20Files/MentalHealth/TRICAREMentalHealth/KaplanIOMpresentation.ashx. (Accessed November 7, 2009).
Maine Office of Licensing and Registration. 2009. Board of Counseling Professionals Licensure—Frequently Asked Questions. http://www.maine.gov/pfr/professionallicensing/professions/counselors/faq_licensee.htm. (Accessed October 12, 2009).
Nebraska Department of Health and Human Services. 2007. Mental health practice. http://www.hhs.state.ne.us/crl/mhcs/mental/mentalhealth.htm. (Accessed October 12, 2009).
Nebraska Department of Health and Human Services Regulation and Licensure. 2004. Licensure of mental health practitioners and the certification of marriage and family therapists,
professional counselors and social workers. Title 172, Chapter 94, July 28. http://www.sos.state.ne.us/rules-and-regs/regsearch/Rules/Health_and_Human_Services_System/Title-172/Chapter-94.pdf. (Accessed October 12, 2009).
OPM (Office of Personnel Management). 2009a. Federal Employees Health Benefits Program handbook: Eligibility for Health Benefits. http://www.opm.gov/insure/health/reference/handbook/fehb06.asp. (Accessed October 28, 2009).
OPM. 2009b. Federal Employees Health Benefits Program Handbook: Government’s Share. http://www.opm.gov/insure/health/reference/handbook/fehb03.asp#govshare. (Accessed October 28, 2009).
OPM. 2009c. Federal Employees Health Benefits Program Handbook: Health Plans. http://www.opm.gov/insure/health/reference/handbook/fehb05.asp#top. (Accessed October 28, 2009).
OPM. 2009d. Federal Employees Health Benefits Program Handbook: Laws and Regulations. http://www.opm.gov/insure/health/reference/handbook/fehb01.asp#lawandregs. (Accessed October 28, 2009).
OPM. 2009e. Federal Employees Health Benefits Program Handbook: Payment of Benefits in Medically Underserved Areas. http://www.opm.gov/insure/health/reference/handbook/fehb05.asp#paymentunder. (Accessed October 28, 2009).
OPM. 2009f. 2009 Guide to federal benefits for federal civilian employees. http://sig.nfc.usda.gov/dprs/RI%2070-01%202009.pdf. (Accessed October 28, 2009).
OPM. 2009g. Federal Employees Health Benefits Program: Choose a Plan & Enroll. http://www.opm.gov/insure/health/planinfo/index.asp. (Accessed October 28, 2009).
PHS-CC (US Public Health Service Commissioned Corps). 2007. CPO Forum: USPHS Scientific and Training Symposium. Presentation by the Chief Health Services Officer. http://usphs-hso.org/cpo/CPO_COA2007.pdf. (Accessed October 28, 2009).
PHS-CC. 2008a. Mental health/behavioral health requirements. http://www.usphs.gov/profession/behavioral/requirements.aspx. (Accessed October 28, 2009).
PHS-CC. 2008b. Profession: Health service. http://www.usphs.gov/profession/healthservices/activities.aspx. (Accessed October 28, 2009).
PHS-CC. 2009a. Profession. http://www.usphs.gov/Profession/. (Accessed October 28, 2009).
PHS-CC. 2009b. Career and assignment manager (CAM) Teams—FAQs. http://www.usphs.gov/transformation/CAM.aspx. (Accessed October 28, 2009).
PHS-CC. 2009c. USPHS physicians professional advisory committee. Minutes from January 28 meeting. http://usphs-ppac.org/PPAC_Meeting_%20Minutes_1-28-09_DRAFT.pdf. (Accessed October 28, 2009).